453
1 UNITED STATES DISTRICT COURT
DISTRICT OF COLUMBIA
2
---------------------------------x
3 CARA LESLIE ALEXANDER et al., :
:
4 Plaintiffs, :
:
5 :
v. : No. 96-2123-RCL
6 :
FEDERAL BUREAU OF INVESTIGATION :
7 et al., :
:
8 Defendants. : Volume 2
---------------------------------x
9
Washington, D.C.
10
Saturday, February 20, 1998
11
12 Continued deposition of
13 GEORGE STEPHANOPOULOS
14 a witness, called for further examination by
15 counsel for Plaintiffs pursuant to notice and
16 agreement of counsel, continuing at
17 approximately 10:06 a.m. at the offices of
18 judicial Watch, 501 School Street S.W.,
19 Washington, D.C., before Joan V. Cain, notary
20 public in and for the District of Columbia,
21 when were present on behalf of the respective
22 parties:
454
1 APPEARANCES:
2 On behalf of Plaintiffs:
3 LARRY KLAYMAN, ESQUIRE
PAUL ORFANEDES, ESQUIRE
4 JASON ALDRICH, ESQUIRE
Judicial Watch
5 501 School Street S.W.
Washington, D.C. 20024
6 (202) 646-5172
7 On behalf of Defendants Federal Bureau of
Investigation and the Executive
8 Office of the President:
9 ELIZABETH J. SHAPIRO, ESQUIRE
Federal Programs Branch
10 Civil Division
United States Department of Justice
11 901 E Street N.W., Room 988
Washington, D.C. 20530
12 (202) 514-5302
13 On behalf of Defendant Hillary Rodham Clinton:
14 PAUL B. GAFFNEY, ESQUIRE
Williams & Connolly
15 725 12th Street N.W.
Washington, D.C. 20005
16 (202) 434-5874
17 On behalf of the White House:
18 MICHELE PETERSON, ESQUIRE
Special Associate Counsel to the President
19 The White House
Washington, D.C. 20500
20 (202) 456-5079
21
22
455
1 APPEARANCES (CONT'D):
2 On behalf of Deponent;
3 STANLEY M. BRAND, ESQUIRE
ROSS NABATOFF, ESQUIRE
4 Brand Lowell & Ryan
923 Fifteenth Street N.W.
5 Washington, D.C. 20005
(202) 662-9700
6
7 C O N T E N T S
8 EXAMINATION BY: PAGE
9 Counsel for Plaintiffs 457
10 STEPHANOPOULOS DEPOSITION EXHIBITS:
11 No. 20 - May 28, 1998, Order 459
12 No. 21 - Memorandum Opinion 460
13 No. 22 - July 27, 1998, Order 474
14 No. 23 - Interrogatory Responses and 479
Objections
15
No. 24 - Plaintiff's First Set of 481
16 Interrogatories
17 No. 25 - Newsweek Article 500
18 No. 26 - Blank Sheet 525
19
20 * * * * *
21
22
456
1 P R O C E E D I N G S
2 THE VIDEOGRAPHER: Good morning.
3 This is the continuing deposition of George
4 Stephanopoulos taken by the counsel for the
5 Plaintiffs in the matter of Cara Leslie
6 Alexander et al. v. Federal Bureau of
7 Investigation, et al. in the U.S. District
8 Court for the District of Columbia, case
9 number 96-2163, held in the offices of
10 Judicial Watch, 501 School Street Southwest,
11 Washington, D.C., on this date, February 20,
12 1999, and at the time indicated on the video
13 screen, which is 10:06 a.m.
14 My name is Sylvanus Holley; I'm the
15 videographer. The court reporter today is
16 Joan Cain from the firm of Beta Reporting.
17 Will counsel now introduce themselves?
18 MR. KLAYMAN: Larry Klayman,
19 chairman and general counsel with Judicial
20 Watch.
21 MR. FITTON: Tom Fitton, President
22 Judicial Watch.
457
1 MR. ALDRICH: Jason Aldrich.
2 MR. ORFANEDES: Paul Orfanedes for
3 Judicial Watch.
4 MR. BRAND: Stanley Brand, counsel
5 for the deponent.
6 MR. NABATOFF: Ross Nabatoff, Brand
7 Lowell & Ryan.
8 MS. SHAPIRO: Elizabeth Shapiro on
9 behalf of the Executive Office of the
10 President.
11 MS. PETERSON: Michelle Peterson
12 from the White House Counsel's office.
13 MR. GAFFNEY: Paul Gaffney on
14 behalf of the First Lady.
15 Whereupon,
16 GEORGE STEPHANOPOULOS
17 was recalled as a witness and, having been
18 first duly sworn, was examined and testified
19 further as follows:
20 EXAMINATION BY COUNSEL FOR PLAINTIFFS
21 CONTINUED
22 BY MR. KLAYMAN:
458
1 Q Just let the record reflect that
2 we're holding the deposition today, which is
3 a Saturday morning, at the request of
4 Mr. Stephanopoulos and his counsel, as an
5 accommodation. We understand you came into
6 town on the weekend, and therefore we wanted
7 to accommodate you this way.
8 Mr. Stephanopoulos, you remember
9 your first deposition, correct?
10 A Yes.
11 Q Did you have an opportunity to
12 review the testimony from your first
13 deposition before you came here today to
14 testify?
15 What are you looking at,
16 Mr. Stephanopoulos? You're pointing at
17 something.
18 MR. KLAYMAN: This is a simple
19 question. I don't understand the problem.
20 THE WITNESS: Yes.
21 BY MR. KLAYMAN:
22 Q And what is it that you were
459
1 looking at? Is there some kind of a set of
2 notes that you're testifying from?
3 A It's the judge's order.
4 Q Which order is that?
5 A The one for this deposition.
6 MR. KLAYMAN: Well, let me ask that
7 the court reporter mark as Exhibit 20 -- we
8 went up to 19 in your first deposition -- an
9 order of the court of May 28, 1998.
10 (Stephanopoulos Deposition
11 Exhibit No. 20 was marked for
12 identification.)
13 MR. KLAYMAN: We have copies.
14 BY MR. KLAYMAN:
15 Q Have you seen this order before,
16 Mr. Stephanopoulos?
17 A Yes, I have.
18 Q Now, at page 2 of the order, it
19 states, "George Stephanopoulos shall conduct
20 a reasonable search for documents responsive
21 to Plaintiffs' subpoena duces tecum
22 previously served on him to the extent
460
1 discussed in the accompanying memorandum
2 opinion. Stephanopoulos shall also submit to
3 additional deposition questioning at a date
4 and time set by Plaintiffs to answer
5 questions regarding any responsive documents
6 produced and the adequacy of his search for
7 responsive documents. Stephanopoulos shall
8 also pay Plaintiffs' attorneys fees and costs
9 resulting from the portion of the motion
10 necessitated by his conduct and from the need
11 to redepose him."
12 You have seen this part of the
13 order before, correct?
14 A Yes, I have.
15 MR. KLAYMAN: I'll show you what
16 I'll ask the court reporter to mark as
17 Exhibit 21.
18 (Stephanopoulos Deposition
19 Exhibit No. 21 was marked for
20 identification.)
21 BY MR. KLAYMAN:
22 Q Have you ever seen this order
461
1 before? This is the memorandum opinion that
2 is referred to in Exhibit 20.
3 A I think so.
4 Q Let me turn your attention to page
5 12 through and including page 26. You can
6 take your time and tell me whether you've
7 ever reviewed this portion of the memorandum
8 opinion and order of May 28, 1998, which is
9 Exhibit 21.
10 A I did, yes.
11 Q When did you first review it?
12 A A while ago. I don't know the
13 exact date.
14 Q Roughly speaking?
15 A Around the time it was issued, I
16 assume.
17 Q Did you read it thoroughly?
18 A I believe so, yeah.
19 Q Turning to page 22 of Exhibit 21,
20 the memorandum opinion and order, at the
21 bottom of page 22 it states, "An examination
22 of the deposition testimony of Stephanopoulos
462
1 leads to the inevitable and overwhelming
2 conclusion that Stephanopoulos did indeed
3 fail to conduct any search for responsive
4 documents in this case."
5 Did you read that?
6 A Yes, sir.
7 Q The judge's statement is correct,
8 is it not? That statement by the court is
9 correct?
10 MR. BRAND: Objection. You're
11 asking him to make a legal judgment.
12 MR. KLAYMAN: No, that's a factual
13 judgment.
14 MR. BRAND: It's the judge's
15 ruling.
16 MR. KLAYMAN: I'm asking the
17 questions. You can make an objection. I ask
18 you not make speaking objections but just put
19 your objection on the record and then we'll
20 get the response.
21 THE WITNESS: I can't speak for the
22 judge. I did do a document search in the
463
1 past and I've done a subsequent one before
2 this deposition, which I'm happy to answer
3 questions on.
4 BY MR. KLAYMAN:
5 Q Are you saying that the judge's
6 ruling here is incorrect?
7 A That's not what I said.
8 Q Well, I want to know. Is the judge
9 correct in his ruling, yes or no?
10 MR. NABATOFF: It's been asked and
11 answered.
12 MR. KLAYMAN: It has not. I want
13 an answer, yes or no, please.
14 MR. BRAND: If you can answer it.
15 THE WITNESS: I can't speak for the
16 judge. I have the greatest respect for Judge
17 Lamberth but I can't speak for him.
18 BY MR. KLAYMAN:
19 Q I'm asking you to speak for
20 yourself.
21 A I've done a document search in the
22 past. I did another one for this deposition.
464
1 Q An examination of the deposition
2 testimony of Stephanopoulos leads to the
3 inevitable and overwhelming conclusion that
4 Stephanopoulos did indeed fail to conduct any
5 search for responsive documents in the case.
6 Are you saying that this finding by the court
7 is incorrect, that you failed to conduct any
8 search for responsive documents in this case?
9 MR. GAFFNEY: Objection, form.
10 BY MR. KLAYMAN:
11 Q Up to the time of your last
12 deposition.
13 MR. NABATOFF: Objection, asked and
14 answered.
15 BY MR. KLAYMAN:
16 Q You can respond.
17 A I answered your question.
18 Q Is that all you'll say?
19 A I've given my response.
20 Q It calls for a yes or no. Are you
21 refusing to give a yes-or-no answer?
22 MR. BRAND: We've objected to the
465
1 form of the question, and he can answer as
2 best he can.
3 BY MR. KLAYMAN:
4 Q The question calls for a yes or no.
5 A I answered your question.
6 Q You're refusing to answer the
7 question yes or no?
8 A I've reviewed this. I've reviewed
9 -- I've done a document search. I did a
10 document search in the past. I did a
11 document search for this deposition.
12 Q When did you do a document search
13 in the past?
14 A Prior to the deposition. I don't
15 have the exact date. It was quite a while
16 ago at this point.
17 Q So is it your position that the
18 court's finding, the one I just read to you,
19 is incorrect?
20 A It's my position that I have
21 complied with the finding of the court and
22 that is what I'm doing.
466
1 Q Is it your view that the court's
2 finding is incorrect, yes or no? I asked for
3 one counsel to make objections, no double
4 teaming.
5 MS. SHAPIRO: I'll object to the
6 relevancy.
7 THE WITNESS: I have the greatest
8 respect for the court, which is why I'm
9 complying with its finding.
10 BY MR. KLAYMAN:
11 Q Mr. Stephanopoulos, are you
12 refusing to answer that question yes or no?
13 A I am complying to the court's order
14 I am submitting to this deposition. I am
15 prepared to answer questions about my
16 document search.
17 Q So you're refusing to answer yes or
18 no?
19 A I've answered your question.
20 MR. KLAYMAN: Certify it.
21 BY MR. KLAYMAN:
22 Q Is it your understanding that as
467
1 you give your testimony today you are in fact
2 in a court proceeding?
3 A I believe so, sure.
4 Q And it's your understanding that
5 you're before the court as we speak?
6 A I guess in some fashion, sure. I
7 haven't thought about it.
8 Q What do you mean by "in some
9 fashion"?
10 A I haven't thought about it much.
11 I'm prepared to answer questions relevant to
12 this order.
13 Q Well, I asked you are you aware
14 that you're in fact before the court as we
15 speak today?
16 A Sure.
17 Q Is it your practice to appear
18 before the court without a coat and tie?
19 MR. BRAND: Objection.
20 BY MR. KLAYMAN:
21 Q Yes or no?
22 MR. BRAND: Larry, we're here
468
1 because the judge has ordered us to answer
2 questions regarding the adequacy of the
3 search for documents. If you want to waste
4 everyone's time asking questions about why
5 George does or doesn't wear a tie, we're not
6 going to continue with this.
7 MR. KLAYMAN: Well, let me give you
8 a proffer here. He says that he respects
9 Judge Lamberth but won't answer questions to
10 get to the truth.
11 MR. BRAND: This isn't about his
12 respect for courts or whether we're in a
13 court or what venue. It's about the adequacy
14 of his search for documents. I'm just
15 telling you we're not going to tolerate this
16 nonsense for however long you want to carry
17 it on. We're here for the judge's order and
18 we're going to respond to it. If you want to
19 waste time about all these other collateral
20 matters, you can do that. We're not going to
21 stay here for that.
22 MR. KLAYMAN: Can I make the
469
1 proffer? And I ask that one of you make an
2 objection at a time. I asked a relevant
3 question the court going to whether an
4 adequate search was conducted. The court
5 made a finding that there was no search at
6 all, and I asked him that question based on
7 the court's finding. It's the most direct
8 and clearest method to get to whether he did
9 one.
10 MR. BRAND: No. You asked him
11 whether he agreed with Judge Lamberth's
12 holding.
13 MR. KLAYMAN: Please let me finish,
14 Mr. Brand. The second thing, he answers the
15 question by saying he has great respect for
16 the court and Judge Lamberth, yet he doesn't
17 come into this court proceeding showing the
18 requisite respect by wearing a coat and tie.
19 I want to know why, and that's relevant to
20 state of mind it's relevant to intent.
21 MR. BRAND: It's totally silly and
22 a waste of everyone's time. Please ask him
470
1 about the adequacy of the search for
2 responsive documents so we can move on;
3 otherwise, Larry, we're going to leave.
4 MR. KLAYMAN: You'll leave contrary
5 to a court order. I'm entitled to ask what
6 his state of mind is today.
7 MR. BRAND: No, we'll leave because
8 you refuse to adhere to the court's order
9 about the scope of this deposition and we
10 need to move on with that.
11 MR. KLAYMAN: Mr. Brand, can I
12 finish what I'm saying? Pay me at least that
13 respect. I want to know whether he is here
14 with the intent to cooperate with this court.
15 He raised the issue in terms of respect.
16 THE WITNESS: On Tuesday, February
17 16 of this week I conducted a search of my
18 files.
19 MR. KLAYMAN: I don't have a
20 question pending.
21 THE WITNESS: And following that
22 search, which took a fair amount of time, I
471
1 found again that I have absolutely no
2 responsive documents concerning FBI files,
3 nothing at all, just as I have found on
4 several previous occasions when I search my
5 files and for many different proceedings. I
6 just want to make sure we have that on the
7 record.
8 BY MR. KLAYMAN:
9 Q Well, we're going to go through it
10 systematically, Mr. Stephanopoulos, but I
11 have a few more questions to ask you, and
12 that's why we're here today.
13 Turn to page 25 of the court's
14 order, Exhibit 21. At the top of the page,
15 "Each time Plaintiffs' counsel questioned
16 Stephanopoulos regarding the search for
17 potentially responsive documents,
18 Stephanopoulos issued the standard response
19 of not being able to remember when he
20 searched for documents. Although he
21 testified that he checked his files with
22 regard to the particular document request at
472
1 issue, when questioned he could not remember
2 when the search had occurred. Given the fact
3 that the subpoena duces tecum was served on
4 February 22, 1998, and the deposition
5 occurred merely two weeks later, on March 9,
6 1998, Stephanopoulos claims of memory loss of
7 simply not believable."
8 Mr. Stephanopoulos, did you forget
9 when you should have remembered when you
10 testified during the initial deposition?
11 MR. GAFFNEY: I object to the form
12 of the question. I also object to sitting
13 for these questions in a deposition when
14 they're plainly outside the scope of the
15 judge's order.
16 BY MR. KLAYMAN:
17 Q You can respond.
18 MS. SHAPIRO: I join that
19 objection.
20 BY MR. KLAYMAN:
21 Q You can respond.
22 A I'll answer questions about my
473
1 February 16 document search.
2 Q You're refusing to answer this
3 question?
4 A I'm prepared to answer questions
5 about the judge's order -- pursuant to the
6 judge's order.
7 Q So you're refusing to answer my
8 last question, yes or no?
9 A I've answered your question.
10 MR. KLAYMAN: Certify it.
11 BY MR. KLAYMAN:
12 Q Down at the bottom in footnote 4,
13 "Stephanopoulos' opposition to plaintiffs'
14 motion to compel makes no mention of these
15 issues whatsoever despite the fact that
16 plaintiffs specifically raised the issue of
17 the adequacy of the search in their motion to
18 compel. This leads the court to conclude
19 that Stephanopoulos failed to conduct any
20 search for responsive documents and did so
21 without explanation and that some of his
22 deposition testimony on this point is not
474
1 truthful."
2 Mr. Stephanopoulos, was some of
3 your deposition testimony on this point not
4 truthful when you testified the first time?
5 A No.
6 Q It was truthful?
7 A Yes, sir.
8 Q So you take issue with Judge
9 Lamberth's finding?
10 A I've answered your question.
11 MR. KLAYMAN: Certify it.
12 I show you what I'll ask the court
13 reporter to mark as Exhibit 22.
14 (Stephanopoulos Deposition
15 Exhibit No. 22 was marked for
16 identification.)
17 BY MR. KLAYMAN:
18 Q Have you ever seen Exhibit 22
19 before? That's an order of July 27, 1998.
20 A I suppose.
21 Q You're not sure?
22 A Probably have.
475
1 Q What do you mean by "probably
2 have"?
3 THE WITNESS: Stan, can I talk to
4 you for a minute?
5 MR. BRAND: Yes.
6 MR. KLAYMAN: I'd like an answer to
7 the question before you take a break. It's
8 not a hard question.
9 MR. BRAND: We need to consult.
10 (Witness conferred with counsel)
11 THE VIDEOGRAPHER: We're going off
12 video record at 10:23.
13 (Discussion off the record)
14 THE VIDEOGRAPHER: We're back on
15 video record at 10:24.
16 BY MR. KLAYMAN:
17 Q Have you seen this document before?
18 A I'm prepared to answer questions
19 about the judge's order.
20 Q You're refusing to answer this
21 question?
22 MR. BRAND: Larry, I don't know
476
1 what this has to do with the adequacy of his
2 search. It's a separate order about
3 attorneys' fees. We don't contest that
4 order. Why don't we again move on with the
5 subject of this deposition?
6 MR. KLAYMAN: It's a foundation to
7 understand upon which basis he is testifying
8 today.
9 MR. BRAND: That has no bearing
10 here. He's here. He's prepared to deal with
11 the subject of the adequacy of the search.
12 MR. KLAYMAN: So he's refusing to
13 answer this question?
14 MR. BRAND: Yes.
15 MR. KLAYMAN: Certify it.
16 BY MR. KLAYMAN:
17 Q Pursuant to the orders that I've
18 just shown to you which, Mr. Stephanopoulos,
19 are foundation questions to make sure that
20 when I ask questions that in fact you'd made
21 an effort to comply with the court's orders
22 and that's why we went through Exhibits 20,
477
1 21, and 22 among other reasons, as stated on
2 the record, I would like to know when it is
3 that you actually carried out what the court
4 was requesting, this new search. When did
5 you do that?
6 A On Tuesday, February 16.
7 Q Now, what were the parameters of
8 this new search? What kinds of documents
9 were you looking for?
10 A The documents talked about in the
11 subpoena.
12 Q Were you looking for any and all
13 documents that refer generally speaking to
14 the controversy known as Filegate?
15 A I was looking for documents in the
16 subpoena.
17 Q I just want to understand what you
18 looked for, which I'm entitled to do, and I'm
19 entitled to ask you a question that relates
20 to the subpoena, not just the subpoena
21 itself. But was it your understanding when
22 you did the search that anything that related
478
1 or referred in any way to the issue of the
2 acquisition of FBI files by The White House
3 during the Clinton years, were you looking
4 for any documents that referred or related in
5 any way to that issue?
6 A Mm-hmm.
7 Q And did you find any?
8 A I did not.
9 Q Was anyone with you when you
10 conducted your search?
11 A No.
12 Q Where did you conduct your search?
13 A In my office at Columbia
14 University.
15 Q Had you conducted a search for
16 documents pursuant to the court's orders, 20,
17 21, and 22, exhibits to this deposition here
18 today, before February 16?
19 A In the past previous -- before my
20 previous deposition, yes.
21 Q So there was no activity for almost
22 a year in searching for the documents?
479
1 A No.
2 MR. KLAYMAN: Now I'll show you
3 what I'll ask the court reporter to mark as
4 Exhibit 23.
5 (Stephanopoulos Deposition
6 Exhibit No. 23 was marked for
7 identification.)
8 BY MR. KLAYMAN:
9 Q Exhibit 23 are interrogatories
10 which were signed on January 26, 1999 and
11 served on January 28, 1999. They're entitled
12 "Nonparty George Stephanopoulos's Responses
13 and Objections to Plaintiffs' First Set of
14 Interrogatories." Have you seen this
15 document before?
16 A Yes, I have.
17 Q When did you see it?
18 A When I reviewed it, when I signed
19 it, just before I came in here today.
20 MS. SHAPIRO: I'll just note an
21 objection that it's outside the scope of the
22 court's order.
480
1 BY MR. KLAYMAN:
2 Q Who prepared the first draft of
3 this document? Did you type it up?
4 A I believe Betsy did.
5 Q Betsy who?
6 A I forgot your last name.
7 MS. SHAPIRO: Shapiro, counsel for
8 the witness.
9 BY MR. KLAYMAN:
10 Q Did you meet with Ms. Shapiro to
11 provide the information for these documents?
12 A I discussed it with her, yes.
13 Q When did you discuss it with her?
14 A Over the phone prior to her typing
15 it up.
16 Q About how soon before these
17 interrogatories were signed by on you on
18 January 26, 1999 did you discuss it with
19 Ms. Shapiro?
20 A I don't know the exact date, but it
21 was close to that date.
22 Q A day or so?
481
1 A I don't know the exact -- close.
2 Q Within a week?
3 A I can't swear to it. I just know
4 it was close.
5 Q In January?
6 A I guess, yeah.
7 Q Now, did you review the document
8 before you signed it thoroughly?
9 A Yes, I did.
10 MR. KLAYMAN: Now, let's take
11 interrogatory number 1, which asks you
12 certain questions about the following, and
13 this is going from the definitional section
14 of the interrogatories, which I'll ask be
15 marked as Exhibit 24.
16 (Stephanopoulos Deposition
17 Exhibit No. 24 was marked for
18 identification.)
19 BY MR. KLAYMAN:
20 Q Have you seen Exhibit 24 before?
21 This is Plaintiffs' first set of
22 interrogatories to nonparty George
482
1 Stephanopoulos?
2 A I think so.
3 Q Well, take your time and let me
4 know definitively yes or no.
5 A Yeah.
6 Q You've seen it?
7 A Mm-hmm.
8 Q When did you see it?
9 A I don't know exactly when, but I've
10 seen it before, though.
11 Q Have you seen it in the last week
12 or so?
13 A I don't think so.
14 THE WITNESS: I got to take a
15 break.
16 BY MR. KLAYMAN:
17 Q I want an answer to this question.
18 A I said I don't think so.
19 Q What's the necessity for a break?
20 A I just need one.
21 Q Are you going to discuss this
22 response with your counsel, when you've seen
483
1 the document?
2 A I don't think so. I just need to
3 take a break.
4 Q Are you going to look at other
5 documents, Mr. Stephanopoulos?
6 MR. KLAYMAN: Off the record.
7 THE VIDEOGRAPHER: We're going off
8 video record at 10:32.
9 (Discussion off the record)
10 THE VIDEOGRAPHER: We're back on
11 video record at 10:34.
12 BY MR. KLAYMAN:
13 Q Mr. Stephanopoulos, you took a
14 break on your own. Did you look at any
15 documents relating to my outstanding question
16 when you took that break?
17 A No.
18 Q Did you have any discussions with
19 counsel about my question when you took the
20 break?
21 A I just had a discussion with
22 counsel. It wasn't about your question,
484
1 actually.
2 Q Did he give you a response to the
3 question?
4 A No, he did not.
5 Q Did he tell you you had seen the
6 document before and when?
7 A I'm prepared to answer questions
8 about the --
9 Q I'm asking you the question.
10 MR. BRAND: I think our discussions
11 are not part of the deposition.
12 MR. KLAYMAN: Is it your position,
13 Mr. Brand, that you fed him an answer to this
14 question, yes or no?
15 MR. BRAND: No. It's my position
16 as his attorney I'm allowed to consult with
17 him and what we say is none of your business.
18 MR. KLAYMAN: It is if you gave him
19 an answer to a question. Did you give him an
20 answer to a question?
21 MR. BRAND: I don't give any
22 witness answers to questions.
485
1 MR. KLAYMAN: Did you tell him that
2 you had --
3 MR. BRAND: If you want to subpoena
4 me, Larry, to a deposition, go ahead and do
5 that but that's the end of my discussion with
6 you about this. What I say to George and
7 what he says to me about this deposition is
8 part of the attorney-client privilege.
9 MR. KLAYMAN: I'm getting into the
10 issue of just how this court proceeding is
11 being respected, Mr. Brand, because I have an
12 outstanding question and the witness leaves
13 with his briefcase.
14 MR. BRAND: The record shows that
15 he answered the last outstanding question.
16 MR. KLAYMAN: And you won't tell me
17 whether you told him the answer to the
18 question.
19 MR. NABATOFF: I'm not going to
20 allow Mr. Brand to answer any more questions.
21 MR. KLAYMAN: I ask one lawyer at a
22 time, Mr. Nabatoff.
486
1 MR. NABATOFF: Well, I had to say
2 something.
3 MR. KLAYMAN: I want to know,
4 simply put, whether this court process is
5 somehow being subverted because I don't
6 understand how a question that simple the
7 witness can get up with a briefcase full of
8 stuff and go to another room and then come
9 back and I'd just asked whether he'd seen the
10 document.
11 MR. BRAND: He answered the
12 question.
13 MR. KLAYMAN: Certify it.
14 BY MR. KLAYMAN:
15 Q I don't know that he did answer the
16 question. Have you seen the document before?
17 A I already answered that but yes, I
18 have, I believe.
19 Q When did you see it?
20 A I don't know exactly when.
21 Q Today?
22 A When you put it in front of me,
487
1 sure.
2 Q Did you ever see it before then?
3 A I'm sure I have, as I've already
4 answered.
5 Q When?
6 A I don't know exactly when.
7 Q Roughly speaking?
8 A I don't know exactly when.
9 MR. BRAND: Again, Larry, this is
10 outside the scope of the judge's order about
11 the adequacy of his search. Again, if you're
12 going to waste our time, at some point it's
13 not productive and it's not within the scope
14 of the order, and we're going to view
15 ourselves as relieved of further obligation
16 to be here.
17 MR. KLAYMAN: You'll make any such
18 determination on your own, not with any court
19 sanction or ours. You can do what you want
20 to do under --
21 MR. BRAND: That's what I'm telling
22 you.
488
1 MR. KLAYMAN: Under what the legal
2 process provides but I'm entitled to ask my
3 questions.
4 MR. BRAND: No, only entitled to
5 ask questions within the scope of the judge's
6 order.
7 MR. KLAYMAN: You don't decide that
8 Mr. Brand.
9 MR. BRAND: You don't, either,
10 Larry.
11 MR. KLAYMAN: We'll put it on the
12 record and let the judge decide. That's what
13 discovery's all about.
14 BY MR. KLAYMAN:
15 Q Did you see this document within
16 the last month?
17 A I don't know exactly when I saw it.
18 I do know that on Tuesday, February 16, I
19 searched my files for any documents relating
20 to the FBI file matter, and I did not find
21 any.
22 Q That's a nonresponse to this
489
1 question. You're refusing to answer my
2 question with regard to Exhibit 24?
3 A I already said I don't know exactly
4 when I saw it but I do know on February 16
5 that I searched my files for any documents
6 related to the FBI file matter and I didn't
7 find any.
8 Q I'm not asking you for recitation.
9 You're not here in the kind of situation,
10 Mr. Stephanopoulos, where you just make a
11 formalized statement. I ask questions, you
12 give the answers, and the answer was --
13 A I'm prepared to answer questions
14 about my February 16 document search.
15 Q Do you have any idea when you saw
16 this?
17 A I've already answered that and I'm
18 prepared to answer questions about my
19 February 16 document search.
20 MR. KLAYMAN: Certify it.
21 BY MR. KLAYMAN:
22 Q When you answered the
490
1 interrogatories, did you know what it was
2 that was the subject of these conversations?
3 A I think I did because I've been
4 asked these questions many times in the past,
5 including at my other deposition, and as I
6 testified in my March 9, 1998, deposition to
7 that.
8 Q Well, 19 of Exhibit 24, this is the
9 definitional section 19, wherein it states,
10 "The term 'conversations' refers to the
11 conversations referred to in your March 9,
12 1998, deposition at 214:17 to 216:10 for
13 which a claim of attorney-client privilege is
14 being made (attached hereto as Exhibit 1) and
15 for which the court held in its May 28, 1998,
16 memorandum opinion," which I showed to you,
17 Exhibit 21: "During the deposition of
18 Stephanopoulos, counsel for Plaintiffs
19 pursued a line of questioning regarding
20 whether Stephanopoulos discussed The White
21 House's reaction to the Filegate matter and
22 its characterization of the matter as a
491
1 mistake. Stephanopoulos Deposition at 214 to
2 216.
3 "The deposition of Stephanopoulos
4 fails to provide the court with sufficient
5 information to ascertain whether the
6 invocation of the attorney-client privilege
7 was appropriate. Plaintiffs may submit a set
8 of narrowly tailored interrogatories to
9 Stephanopoulos seeking information pertaining
10 to this issue and whether the invocation of
11 the attorney-client privilege was proper.
12 Stephanopoulos should fully support any
13 claims of privilege in response to these
14 interrogatories in a manner that permits the
15 court to ascertain whether the privilege
16 claim applies, if necessary."
17 Do you see that?
18 A Mm-hmm.
19 Q And that was the reason I was
20 asking you those questions, to see whether
21 you had seen exactly what the court ruled.
22 Were you aware of what the court ruled
492
1 specifically with regard to the
2 interrogatories that were posed upon you?
3 That question's not unreasonable, is it?
4 MR. BRAND: It's outside the scope
5 of the deposition.
6 BY MR. KLAYMAN:
7 Q Is that question unreasonable,
8 Mr. Stephanopoulos?
9 A I don't know whether it's
10 reasonable or not. I do know that on
11 February 16 I searched my office for
12 documents pursuant to this.
13 Q And that's all you're going to say?
14 A I'm prepared to answer questions
15 about it.
16 MR. KLAYMAN: Certify it.
17 BY MR. KLAYMAN:
18 Q Now, at the time that you signed
19 these interrogatories, which are Exhibit 23,
20 you had not done another search as the court
21 required you to do through the orders of May
22 28, 1998, correct?
493
1 A I had done a search in the past,
2 and I've done a search subsequent to prepare
3 for this deposition.
4 Q The court ruled that your first
5 search was not done, correct? That was the
6 court's finding.
7 A I'm prepared to answer questions
8 about my February 16 document search.
9 Q Yes or no?
10 A As I said, I'm prepared to answer
11 questions about my February 16 document
12 search.
13 Q You're refusing to answer that
14 question?
15 A I am answering questions. I'm
16 trying to answer questions about the judge's
17 order.
18 MR. KLAYMAN: All right. Certify
19 it.
20 BY MR. KLAYMAN:
21 Q It's clear you're refusing to
22 answer the question. At the time that you
494
1 answered these interrogatories, you had not
2 done the search that the court required you
3 to do in his orders of May 28, 1998?
4 A I have searched my files in the
5 past. I have searched my files many, many
6 times, most recently on February 16.
7 Q But you had not done the search
8 that the court ordered on May 28, 1998? The
9 second search, you hadn't done that?
10 MR. BRAND: When?
11 MR. KLAYMAN: At the time he
12 answered these interrogatories.
13 THE WITNESS: No, I had not.
14 BY MR. KLAYMAN:
15 Q So in these interrogatories,
16 looking at interrogatory number 1, you
17 answered, "As I testified in my March 9,
18 1998, deposition, I do not remember a
19 specific conversation or conversations with
20 White House Counsel's Office relating to the
21 FBI files matter. Any such conversations
22 with White House Counsel's Office would have
495
1 taken place in The White House complex. I do
2 not remember the date or time of any such
3 conversations, but it likely would have
4 occurred shortly after the FBI files matter
5 became public in early June 1996 and probably
6 would have occurred by telephone."
7 Now, in essence, what you're saying
8 is, I don't remember a specific conversation
9 or conversations about Filegate, correct?
10 A The testimony speaks for itself.
11 Q That's a correct characterization,
12 is it not?
13 A I'll let my testimony speak for
14 itself.
15 Q Well, taking your testimony at what
16 it says, is it not true that, if you had done
17 a second search and found documents, they may
18 have refreshed your recollection, correct?
19 A I have done several searches, most
20 recently on February 16, and have not found
21 any responsive documents, so that is not true
22 because -- I mean, you're asking a
496
1 hypothetical. If there are no documents,
2 they can't refresh my recollection.
3 Q Well, let me ask you this. At the
4 time that you answered the interrogatories,
5 and I'll let all the responses speak for
6 themselves, you made no effort to find out
7 whether there were other documents that the
8 judge had ordered that you search that might
9 have refreshed your recollection to be able
10 to answer the interrogatories?
11 A There are no documents. You know,
12 there are no documents.
13 Q So what you're basically saying is
14 that in the court's orders of May 28, 1998,
15 that the judge's findings are wrong --
16 A That's not what I said. I said
17 there's no documents.
18 Q And that you consider your first
19 search more than adequate from which you can
20 glean all knowledge about any questions that
21 you're asked about Filegate, correct?
22 A I've answered your questions. I've
497
1 testified about it and I'm prepared to
2 testify about it.
3 Q Answer my question.
4 A I don't know what the question was.
5 Q The question was you have a court
6 saying that you didn't do a search. The
7 court orders you to do a search May 28, 1998,
8 of last year. The court's made a finding
9 that you did no search, and yet you answer
10 interrogatories that call for answers that
11 could be amplified or at least refreshed if
12 in fact you carried out the court's order of
13 May 28 and did the second search?
14 MR. BRAND: What's the question,
15 Larry?
16 BY MR. KLAYMAN:
17 Q And the question is,
18 Mr. Stephanopoulos, why didn't you do the
19 search that the court ordered before you
20 answered these interrogatories?
21 A I did the search for this
22 deposition, which is what I was supposed to
498
1 do.
2 Q So you felt you were under no
3 obligation to do the search the court ordered
4 before answering these interrogatories?
5 A This is my testimony from March 9.
6 It is correct testimony. It is truthful
7 testimony, and nothing in my search would
8 have changed it because I have searched
9 before.
10 Q So what you're saying is that the
11 court's order asking you to do the second
12 search was futile, meaningless? That was
13 your opinion, correct?
14 MR. BRAND: Objection. He said
15 what he said. You've got to stop putting
16 testimony in his mouth. If you want to
17 testify, come over and swear an oath and
18 testify, but I'm not going to let you say
19 what he said. What he said is on the record
20 now.
21 MR. KLAYMAN: I ask the questions.
22 MR. BRAND: You don't know how to
499
1 ask the questions.
2 BY MR. KLAYMAN:
3 Q Is it your view at the time you saw
4 the judge's orders on May 28, 1998, that in
5 your opinion it was futile to have done a
6 second search?
7 A No, I've done a second search.
8 Q So it wasn't futile?
9 A I've done a second search.
10 Q Because the court made a reasonable
11 finding --
12 A Because the court told me to. No,
13 because the court told me to.
14 Q And you didn't feel that the
15 court's orders of May 28 required you to do a
16 second search before you answered
17 interrogatories that were posed upon you,
18 Exhibit 23?
19 A I answered the questions to the
20 best of my ability. I've complied with the
21 court's order.
22 Q Mr. Stephanopoulos, have you ever
500
1 called his court a kangaroo court?
2 A I don't know.
3 Q You don't remember?
4 A No.
5 MR. KLAYMAN: I'll show you what
6 I'll ask the court reporter to mark as
7 Exhibit 25.
8 (Stephanopoulos Deposition
9 Exhibit No. 25 was marked for
10 identification.)
11 BY MR. KLAYMAN:
12 Q Exhibit 25 is an article which
13 appeared in Newsweek on May 11, 1998. The
14 title of the article is "A Legal Bomb
15 Thrower." Larry Klayman, right-wing lawyer is
16 on the a mission to shake up The White House
17 with a host of subpoenas, and in the third
18 column you're quoted saying it's a kangaroo
19 court. You were referring to this court,
20 were you not?
21 A No, I'm sure I was referring to
22 you.
501
1 Q I am the court?
2 A You know, it's a figure of speech.
3 Q You are accurately quoted, are you
4 not?
5 A I suppose so. This is the same way
6 that you're quoted saying we're filling a
7 market niche. What does that have to do with
8 a judicial proceeding?
9 Q I'm asking you the questions,
10 Mr. Stephanopoulos. You're quoted as saying,
11 "He's out of control." You're referring to
12 Larry Klayman, correct?
13 A Oh, I suppose so, yes.
14 Q "Says Stephanopoulos, now a
15 commentator for ABC news and a contributor to
16 Newsweek," and then you add, "It's a kangaroo
17 court." You did make that statement, didn't
18 you?
19 A I'm sure I did. It's quoted there
20 and just as sure as I am that I on February
21 16, 1999, searched my files for any
22 responsive documents.
502
1 Q So you view Judge Lamberth and his
2 court as a kangaroo court, correct?
3 A No, that's not what I said.
4 Q Are you retracting your statement
5 that you made here that you said you made?
6 A No. What I said three sentences
7 ago is that I was talking about you, not
8 about Judge Lamberth.
9 Q Well, your quote uses the word
10 court, does it not?
11 A As I said, it's a figure of speech.
12 You know, just ask the questions.
13 Q Are you refusing to answer that?
14 A No, I've answered it.
15 Q So you didn't really mean to use
16 the word "court"?
17 A That's not what I said. I stand by
18 my statement.
19 Q Now, let's go back to your search
20 on February 16.
21 I take it at some point in time you
22 moved from Washington to New York City, when
503
1 you left the administration, correct?
2 A I've answered these questions in my
3 previous deposition.
4 Q I'm laying a foundation.
5 A I've answered these questions in my
6 previous deposition. I'm prepared to answer
7 questions about the adequacy of my document
8 search on February 16. I'm not going to redo
9 my whole last deposition. The judge has a
10 very specific order.
11 Q I'm laying a foundation. Are you
12 refusing to answer?
13 A I've answered your question.
14 MR. KLAYMAN: Certify it.
15 BY MR. KLAYMAN:
16 Q What I want to know,
17 Mr. Stephanopoulos, is why it is you limited
18 your search only to your office at Columbia
19 University, the one the court ordered on May
20 28, 1998.
21 A Because, if I had any documents,
22 that's where they would be.
504
1 Q Well, and I want to be able to show
2 that documents were located elsewhere.
3 That's why I'm asking these questions.
4 A I've answered the questions.
5 Q Are you refusing to answer any
6 more?
7 A I'm prepared to answer questions
8 about the February 16 document search.
9 Q Well, when you left The White
10 House, did you take any documents with you?
11 A I've answered those questions
12 before in my previous deposition. I'm not
13 going to do this again, Larry. I will answer
14 questions about the February 16 document
15 search. We're not going to just do a whole
16 new deposition here.
17 Q I can go backwards. If you want to
18 go backwards, I'll go backwards. You did the
19 search in your Columbia University office.
20 Why is it you limited the search to that
21 office?
22 A That's where the documents, if
505
1 there were any, would be, but there weren't
2 any.
3 Q Now, do you have an apartment in
4 New York City?
5 A I do have an apartment in New York
6 City.
7 Q You do have documents in that
8 apartment?
9 A I have books. I have lots of
10 things in my apartment in New York City. I
11 do not have anything responsive to this
12 subpoena.
13 Q You have been writing a book,
14 correct?
15 A And the book does not talk about
16 the FBI files outside of one sentence, which
17 I've said here.
18 Q You wrote part of that book in your
19 apartment in New York City, correct?
20 MR. BRAND: We're going to object
21 and I'm going to instruct him not to answer.
22 This has nothing to do with the adequacy of
506
1 his search as defined in the judge's order.
2 We've litigated the privilege that George has
3 an author and as a journalist. We're not
4 going to plow that ground again.
5 MR. KLAYMAN: We're not plowing any
6 ground again.
7 MR. BRAND: You're asking him
8 questions not on the relevant subject for
9 today, Larry. You're wasting everyone's
10 time.
11 MR. KLAYMAN: Mr. Brand, the court
12 is on record as to how it viewed the prior
13 deposition. I'm not going to get into that
14 and the court's on record as to what these
15 orders are. Please don't interrupt me.
16 MR. BRAND: I'm happy with the
17 court. I have no problem with the court.
18 MR. KLAYMAN: I didn't ask you a
19 question, Mr. Brand. I didn't ask whether
20 you're happy or unhappy. I'm just asking you
21 to have your client answer the questions and
22 I'll give you a proffer here. He just
507
1 testified that one part of his book dealt
2 with Filegate. That's enough for me to ask
3 whether he wrote parts of his book in his
4 apartment in New York City.
5 MR. BRAND: No, it's not. Move on,
6 Larry.
7 MR. KLAYMAN: Certify it.
8 BY MR. KLAYMAN:
9 Q Did you write --
10 MR. BRAND: I will tell you, Larry,
11 that we will also go for costs on this
12 because this is outside the scope. It's an
13 abuse of process and it's a waste of time and
14 I'm just putting you on notice now we're
15 going to go to for costs now.
16 MR. KLAYMAN: And we'll go for
17 attorney's fees and costs for filing a
18 frivolous motion, so you're on notice as
19 well.
20 BY MR. KLAYMAN:
21 Q Did you write your book in part in
22 your apartment in New York City?
508
1 MR. BRAND: I object and I instruct
2 him not to answer.
3 MR. KLAYMAN: Certify it.
4 BY MR. KLAYMAN:
5 Q Now, part of the book, as you
6 stated, does have a sentence on Filegate,
7 correct?
8 MR. BRAND: I object and instruct
9 him not to answer.
10 MR. KLAYMAN: Certify it.
11 BY MR. KLAYMAN:
12 Q You did not search your apartment
13 in response to the judge's orders of May 28,
14 1998?
15 MR. BRAND: Objection. That's a
16 mischaracterization of his testimony.
17 BY MR. KLAYMAN:
18 Q You can respond.
19 A I live in my apartment. I know
20 what's in my apartment.
21 Q But you didn't do a search, as the
22 court ordered?
509
1 A I live in my apartment. I'm there
2 every day. I know what's in my apartment. I
3 have nothing in my apartment about FBI files.
4 Q Yes or no, you did not do a search?
5 A I've answered your question.
6 MR. KLAYMAN: Certify it.
7 BY MR. KLAYMAN:
8 Q You have an office here in
9 Washington at ABC; is that correct?
10 A No, that's not correct, actually.
11 Q Do you have an office in
12 Washington?
13 A No.
14 Q Is there a place where you stay
15 when you come to Washington to do This Week?
16 A Yes, I do sleep here on Saturday
17 nights.
18 Q Is that a hotel, an apartment, a
19 condominium?
20 A I don't think that's any of your
21 business.
22 Q I'm not asking you for the address.
510
1 A I have a small apartment in
2 Washington, yes.
3 Q And you rent it yourself?
4 A That's certainly none of your
5 business.
6 Q Did you search that apartment in
7 response to the judge's order?
8 A I don't have anything in that
9 apartment. It's a very small apartment.
10 It's actually one room. I know for a fact I
11 don't have anything there.
12 Q You do have documents there, don't
13 you?
14 A I don't think so.
15 Q You're not sure?
16 A I don't have any documents related
17 to FBI files, certainly. There may be some
18 old newspapers there.
19 Q You have documents related to other
20 things there, don't you?
21 A I just answered your questions.
22 Q You're refusing to answer that
511
1 question?
2 A I just answered your question.
3 Q You're refusing to answer it?
4 A I just answered it.
5 Q Do you have documents related to
6 other matters in that apartment?
7 A I said there might be some old
8 newspapers in there. There's some books. I
9 don't have anything related to FBI files.
10 Q Any letters in that apartment?
11 A I don't think so no.
12 Q You're not sure?
13 A I said I don't think so.
14 Q Do you have any memoranda in that
15 apartment?
16 A I don't think so.
17 Q When you left The White House, did
18 you take documents from The White House and
19 first put them in that apartment?
20 A No.
21 Q You did leave The White House with
22 some documents, didn't you?
512
1 MS. SHAPIRO: Objection, form.
2 THE WITNESS: I've answered that
3 question in my previous deposition. I'm
4 prepared to answer questions about the
5 adequacy of my document search.
6 BY MR. KLAYMAN:
7 Q You're refusing to answer this
8 question?
9 A I've already answered it.
10 MR. KLAYMAN: Certify it.
11 BY MR. KLAYMAN:
12 Q You did not search the apartment in
13 Washington pursuant to the judge's orders,
14 correct?
15 A I know what's in the apartment in
16 Washington. I know I have no documents
17 pursuant to the subpoena in that apartment.
18 It's a one-room apartment. I just don't have
19 anything there.
20 Q Have you ever written portions of
21 your book in that apartment?
22 MR. BRAND: Objection.
513
1 MR. KLAYMAN: Are you asking him
2 not to answer?
3 MR. BRAND: Yes.
4 MR. KLAYMAN: Certify it.
5 BY MR. KLAYMAN:
6 Q Did you write your book on a laptop
7 computer?
8 MR. BRAND: Objection.
9 BY MR. KLAYMAN:
10 Q Yes or no?
11 MR. BRAND: I'm going to instruct
12 him not to answer.
13 BY MR. KLAYMAN:
14 Q Did you search your laptop
15 computer?
16 MR. BRAND: Objection.
17 MR. KLAYMAN: Are you instructing
18 him not to answer?
19 MR. BRAND: Yes.
20 MR. KLAYMAN: Certify it.
21 BY MR. KLAYMAN:
22 Q Have you used your laptop computer
514
1 for things other than writing your book?
2 MR. BRAND: Objection.
3 MR. KLAYMAN: Instructing him not
4 to answer?
5 MR. BRAND: Yes.
6 MR. KLAYMAN: Certify it.
7 BY MR. KLAYMAN:
8 Q Up through the date of your last
9 deposition, did you ever use a desktop
10 computer?
11 MR. BRAND: Objection.
12 MR. KLAYMAN: Are you instructing
13 him not to answer?
14 MR. BRAND: Yes.
15 MR. KLAYMAN: Certify it.
16 BY MR. KLAYMAN:
17 Q Did you search desktop computers
18 pursuant to the judge's order of May 28,
19 1998?
20 A I've searched. I didn't have
21 anything about FBI files on any computer.
22 Q Did you make a specific search?
515
1 A I don't even know what that means
2 exactly but I know I don't have anything in
3 the computer because if it was in the
4 computer I would have had to put it in there.
5 Q But you never made a search?
6 A I'm the only one who has my
7 computer.
8 Q Answer yes or no. You didn't do a
9 specific search?
10 A I didn't have my White House
11 computer and I didn't take anything having to
12 do with any White House computer from The
13 White House.
14 Q But you have used a desktop since
15 you've left, correct?
16 A I don't know what you mean by that
17 exactly but I have used computers since I've
18 left, and I've never discussed the FBI files
19 matter on a computer since I've left and it
20 has nothing to do with this subpoena.
21 Q Now, you've appeared on This Week
22 with Sam Donaldson, Cokie Robertson a number
516
1 of times since you've left, correct, since
2 you left The White House?
3 MR. BRAND: Objection.
4 MR. KLAYMAN: I'm laying a
5 foundation.
6 BY MR. KLAYMAN:
7 Q Respond.
8 MR. BRAND: Object to the question
9 and instruct the witness not to answer.
10 Totally outside the scope of this deposition.
11 BY MR. KLAYMAN:
12 Q Since you've left The White House,
13 you have discussed the FBI files matter on
14 This Week and on ABC's morning shows and
15 other shows, correct?
16 MR. BRAND: Objection.
17 BY MR. KLAYMAN:
18 Q From time to time you have
19 discussed the FBI files matters?
20 MR. BRAND: Objection.
21 BY MR. KLAYMAN:
22 Q You can respond.
517
1 MR. BRAND: No, he can't.
2 MR. KLAYMAN: Certify it.
3 BY MR. KLAYMAN:
4 Q And what I'm trying to get at,
5 Mr. Stephanopoulos, is that you may have
6 recorded notes or you may have written
7 memoranda or you may have had some other type
8 of documentation of what you were going to
9 say on those shows, correct?
10 A No, I didn't. I can say that, no,
11 that's not collect.
12 Q But you never searched any of that
13 stuff at ABC or in your apartments to find
14 out whether you did in response to those
15 judge's orders on May 28, 1998, correct?
16 A I'm the only one who could have
17 written them. I know I didn't write them. I
18 mean, is there some magic genie who came into
19 my computer?
20 Q Here's the problem I'm having.
21 You've had a bad memory about discussions you
22 had with FBI files?
518
1 A That's not true.
2 Q You say you can't remember
3 specifics, right?
4 A That's a mischaracterization.
5 Q Let's go back to your
6 interrogatories. I read you the answer to
7 number 1. Question number 2, "For each such
8 conversations state everything that was said
9 during the conversation by each of the
10 participants concerning or relating in any
11 way to The White House's reaction to the
12 Filegate matter and its characterization of
13 the matter as a mistake."
14 Response: "As I testified in my
15 March 9, 1998 deposition, I do not remember
16 the substance of any specific conversation or
17 conversations beyond the characterization by
18 The White House Counsel's Office that the FBI
19 files matter occurred as a result of a
20 mistake and it was not authorized at high
21 levels of The White House."
22 A I stand by that statement.
519
1 Q Now, you can't remember the
2 specifics of any conversation with regard to
3 the FBI files matter, correct?
4 A My testimony speaks for itself.
5 Q In fact, your memory isn't very
6 good on that, is it?
7 A I disagree with that.
8 Q So here in these interrogatories
9 and in your testimony on March 9 you say I
10 have a bad memory, I can't remember anything
11 specific about Filegate, yet you remember
12 clearly that you don't have any documents and
13 therefore you don't have to search certain
14 areas. That's correct, isn't it?
15 A I have searched.
16 Q That's a correct characterization,
17 isn't it?
18 A I had searched and I've been
19 deposed on this several times and I've
20 searched most recently on February 16 and I'm
21 prepared to answer questions about that.
22 Q Will you answer that question? How
520
1 do you explain that dichotomy that you can't
2 remember anything about specific
3 conversations or anything specifically about
4 Filegate yet you know definitely that you
5 don't have any documents?
6 MS. SHAPIRO: Objection to form.
7 BY MR. KLAYMAN:
8 Q How do you explain that?
9 A I've answered your question.
10 MR. KLAYMAN: Certify it.
11 BY MR. KLAYMAN:
12 Q Did you search your laptop pursuant
13 to the court's orders?
14 A I have searched my office. I have
15 nothing on my laptop.
16 Q You didn't search, did you?
17 A I know what's in my laptop. I work
18 on it all the time. I know what's in it.
19 Q But you didn't search?
20 A That's not true. I know what's in
21 my laptop.
22 Q You didn't search responsive to the
521
1 judge's order?
2 A What is in my laptop I put in my
3 laptop. There is nothing about FBI files.
4 MR. KLAYMAN: I understand the
5 answer. Certify it.
6 BY MR. KLAYMAN:
7 Q Do you have computer disks that you
8 keep, floppy disks?
9 A None from The White House.
10 Q Did you have any that you had
11 manufactured before your last deposition?
12 A I have no computer disks from The
13 White House that have anything to do with FBI
14 files matter.
15 Q But did you have computer disks
16 before your last deposition?
17 A I don't know what that means
18 exactly.
19 Q Were there computer disks in
20 existence that had documents on them?
21 A I don't know what that means.
22 Q That were in your possession,
522
1 custody, or control?
2 A Nothing having anything to do with
3 FBI files matter.
4 Q You never searched them, did you,
5 in response to the subpoena?
6 A That's not true. I know what I put
7 on the computer disks. I know what I have.
8 I don't have anything and I know I didn't
9 take any from The White House.
10 Q But you didn't do a search?
11 A I'm the only one who can put
12 something into my computer.
13 Q Well, suppose you have a bad memory
14 that maybe you wrote something about Filegate
15 on there after you left?
16 A I didn't and after I left has
17 nothing to do with this subpoena.
18 Q When I ask you about a major
19 scandal in this administration, you can't
20 remember anything. You were there when it
21 broke, correct?
22 MS. SHAPIRO: Objection to form.
523
1 THE WITNESS: I have testified on
2 the FBI files matter many, many times. I
3 disagree with your characterization. I think
4 it was a mistake, as I've said many, many
5 times, and in fact most recently even Judge
6 Starr has found no criminal wrongdoing in the
7 FBI file matter and certainly no involvement
8 by me.
9 Q I didn't ask you about Judge Starr.
10 I know you're a great opponent of his but I
11 didn't ask you about Judge Starr?
12 A That's not what I said.
13 Q I asked you about this case.
14 A And on this case I've answered all
15 of your questions and I'm prepared to answer
16 questions about the judge's order.
17 Q How can you explain that you
18 definitively know you never wrote anything
19 down about Filegate? You won't answer
20 questions as to whether you've discussed file
21 gate and your various activities since you
22 left the White House and you know
524
1 definitively nothing is on your computer
2 disks, yet you don't remember anything about
3 the time in the White House?
4 A No.
5 Q Other than the fact that the word
6 "Filegate" was used?
7 MS. SHAPIRO: Objection to form,
8 vague.
9 BY MR. KLAYMAN:
10 Q My characterization's accurate,
11 isn't it?
12 A No.
13 Q Why isn't it accurate?
14 A I'm prepared to answer questions
15 about my document search.
16 MR. KLAYMAN: All right, certify
17 it.
18 BY MR. KLAYMAN:
19 Q Did you keep an inventory of what
20 you looked at in your Columbia University
21 office on February 16, 1999?
22 A What does that mean?
525
1 Q Did you make a list of where you
2 searched in your office?
3 A No.
4 Q Where is your office located?
5 A It's in the International Affairs
6 Building.
7 Q What's the number of it?
8 A 1315.
9 Q What's in your office?
10 A Desk, chair, books, phone.
11 Q File cabinets?
12 A File cabinets.
13 Q What kind of file cabinets?
14 A File cabinets. I don't know what
15 you mean.
16 MR. KLAYMAN: I'll ask this be
17 marked Exhibit 26.
18 (Stephanopoulos Deposition
19 Exhibit No. 26 was marked for
20 identification.)
21 BY MR. KLAYMAN:
22 Q I'm not asking you to draw anything
526
1 to scale but draw a configuration of your
2 office.
3 MR. BRAND: Objection. We're not
4 going to go through that, Larry.
5 MR. KLAYMAN: You're not going to
6 let him do this?
7 MR. BRAND: No. I'm not going to
8 have you order him to make drawings of his
9 office.
10 MR. KLAYMAN: I won't hold him to
11 scale.
12 MR. BRAND: We're not going to let
13 him do that.
14 MR. KLAYMAN: Certify it. We'll
15 keep it as 26 and note the refusal.
16 BY MR. KLAYMAN:
17 Q What kind of file cabinets do you
18 have?
19 A They're file cabinets. They have
20 folders in them, and I went through all the
21 folders, and there's nothing on FBI files.
22 Q How many folders do you have?
527
1 A I would estimate probably -- I
2 can't swear to the exact number, but it would
3 probably be between 40 and 60.
4 Q And how deep are each of these
5 folders, approximately?
6 A Some have two or three pages in
7 them; some have more.
8 Q Are these folders that you took
9 from the White House?
10 A They're all mixed up now but they
11 include stuff that may have come from the
12 White House. You know, not -- sometimes
13 they're just clippings like this.
14 Q Now, sometimes the documents in
15 those folders are from other sources,
16 correct?
17 A Yeah, I think so.
18 Q Faxes from James Carville?
19 MS. SHAPIRO: Objection, form.
20 BY MR. KLAYMAN:
21 Q Correct?
22 A I don't know exactly. I know there
528
1 was nothing -- there was nothing when I went
2 through all the folders on Tuesday, February
3 16, there was nothing having to do with the
4 FBI files matter.
5 Q But there are documents from
6 Carville in those folders, aren't there?
7 A I don't know. I doubt it but I
8 don't know.
9 Q There are some documents that you
10 got from Williams & Connolly in those
11 folders, correct?
12 MS. SHAPIRO: Objection, relevancy.
13 MR. GAFFNEY: Objection, form.
14 BY MR. KLAYMAN:
15 Q You can respond.
16 A I don't know but nothing having to
17 do with FBI files.
18 Q You do have documents from Williams
19 & Connolly in those files, correct?
20 MR. GAFFNEY: Object to the form of
21 the question.
22 THE WITNESS: I don't know, but I
529
1 know I don't have anything having to do with
2 FBI files.
3 BY MR. KLAYMAN:
4 Q You have documents from Terry
5 Lenzner in those files?
6 A I doubt it. In fact, I know I
7 don't have anything from Terry Lenzner.
8 Q Or his firm, IGI?
9 A Certainly not.
10 Q You have files that have been given
11 to you by the White House since you've left?
12 You have documents that have been provided by
13 the White House since you left the White
14 House in those files?
15 A Nothing on FBI files.
16 MR. GAFFNEY: I object to the form
17 of the question.
18 BY MR. KLAYMAN:
19 Q Does the White House routinely send
20 you its press releases since you've left?
21 MS. SHAPIRO: Objection to form and
22 relevancy.
530
1 BY MR. KLAYMAN:
2 Q You can respond.
3 A No.
4 Q You've never gotten a press release
5 from the White House since you've left?
6 A I didn't say that. I'm sure I have
7 at some time but not routinely.
8 Q And some of those press releases
9 have dealt with Filegate, correct?
10 A No.
11 MR. GAFFNEY: Objection to form.
12 BY MR. KLAYMAN:
13 Q In those file folders you have
14 documents from the Democratic National
15 Committee, correct?
16 MS. SHAPIRO: Objection to form and
17 relevancy.
18 THE WITNESS: I have nothing
19 related to FBI files matter.
20 BY MR. KLAYMAN:
21 Q But you do have documents from the
22 Democratic National Committee?
531
1 A I don't know exactly.
2 MR. GAFFNEY: Objection to form.
3 Q In those files you have documents
4 sent to you by Sid Blumenthal, correct?
5 A I don't think so.
6 MR. GAFFNEY: Objection to form.
7 BY MR. KLAYMAN:
8 Q Is that funny?
9 A I answered your question.
10 Q You're not sure whether you have
11 documents from Mr. Blumenthal?
12 A I certainly don't remember seeing
13 any and certainly nothing to do with FBI
14 files.
15 Q You have talked to Mr. Blumenthal
16 since you've left, correct?
17 MS. SHAPIRO: Objection.
18 MR. GAFFNEY: Objection to form.
19 BY MR. KLAYMAN:
20 Q Yes or no?
21 MR. BRAND: Objection and instruct
22 not to answer. Outside the scope of this
532
1 case.
2 BY MR. KLAYMAN:
3 Q The White House has commented on
4 Filegate since you've left, correct?
5 MR. BRAND: Objection and instruct
6 him not to answer. Larry, we're really
7 running the clock here. I think you need to
8 wrap this up. If you have questions about
9 the adequacy of the search, let's get to it
10 or else we will terminate this deposition
11 soon because this is getting way out of line.
12 MR. GAFFNEY: Objection to form.
13 MR. KLAYMAN: Mr. Brand, I don't
14 wish to have to file motions or take up the
15 court's time or take up our time, but if
16 you're going to terminate this deposition you
17 do so at your own risk. We have not gotten
18 one document pursuant to the court's orders,
19 not one, and I'm entitled to do a voir dire
20 to find out where such documents may be
21 located.
22 MR. BRAND: You've ranged all over
533
1 the landscape, Larry, to his book, to his
2 activities since he left The White House.
3 You haven't asked questions except for a few
4 about the scope of the order, and, again,
5 we're not going to sit here all day while you
6 satisfy your prurient interest about other
7 matters not in litigation.
8 MR. KLAYMAN: What do you mean by
9 prurient interest?
10 MR. BRAND: Whatever interest you
11 have.
12 BY MR. KLAYMAN:
13 Q Do you have computer disks in that
14 office?
15 MR. BRAND: That's been asked and
16 answered.
17 BY MR. KLAYMAN:
18 Q I didn't say in that office.
19 MR. BRAND: Which office?
20 MR. KLAYMAN: Columbia University.
21 THE WITNESS: Nothing from The
22 White House.
534
1 BY MR. KLAYMAN:
2 Q Do you have a Dictaphone in that
3 office?
4 A Nothing from The White House.
5 Q Did you search the Dictaphone?
6 A There's nothing from The White
7 House.
8 Q I didn't ask you about the White
9 House. Did you search the Dictaphone in
10 response to the court's orders?
11 A I don't have a Dictaphone.
12 Q That's what I asked you, do you
13 have a Dictaphone in that office. The
14 answer's no?
15 A I don't have a Dictaphone, no.
16 Q Do you have a little tape recorder?
17 A I don't know if it's in that office
18 or not. I know I had a research assistant
19 who taped my classes.
20 Q You do have a tape recorder
21 sometimes you make your own verbal notations
22 on, correct?
535
1 A No, that's not what I said.
2 Q Have you ever done that since
3 you've left The White House?
4 A No. I don't know what that has to
5 do with the adequacy of my document search on
6 FBI files.
7 Q Since the time of your last
8 deposition to today have you talked with
9 anyone other than your lawyers about
10 Filegate?
11 A I don't know what that means
12 exactly but I don't think so.
13 MR. GAFFNEY: Objection, form.
14 BY MR. KLAYMAN:
15 Q You're not sure?
16 A I just answered I don't know what
17 the question means exactly but I don't think
18 so.
19 Q Since the time of the last
20 deposition and today, have you talked to
21 anyone other than your lawyers about the
22 court's orders of May 28?
536
1 A No.
2 Q Did you ever ask anyone at ABC to
3 look for documents that you created that
4 might be responsive to the subpoena and the
5 court's orders?
6 A No, I didn't create any.
7 Q You didn't ask anybody at ABC, did
8 you?
9 A I don't have files at ABC.
10 Q You sit there on the set of This
11 Week with a pen, correct?
12 MR. BRAND: Objection.
13 BY MR. KLAYMAN:
14 Q Every week you sit there with a pen
15 in your hand, correct?
16 A I'm ready to go.
17 MR. BRAND: Objection.
18 BY MR. KLAYMAN:
19 Q You're ready to go,
20 Mr. Stephanopoulos?
21 A I'm prepared to answer questions
22 pursuant to the order. I'm not prepared to
537
1 answer questions about whether or not I hold
2 a pen on This Week.
3 Q The question is you did talk about
4 Filegate before you received the subpoena in
5 this case, correct, when you were appearing
6 on This Week?
7 A I don't know that I did.
8 Q You don't know one way or the
9 other?
10 A You know, I don't know what you
11 mean by talking about Filegate. I know that
12 I didn't talk about anything having to do
13 with this judge's order here.
14 Q But you never actually reviewed
15 what you said on your appearances on This
16 Week before you responded to the subpoena the
17 first time, correct?
18 A I don't know what you're talking
19 about.
20 Q You said you're not sure whether
21 you talked about Filegate or not when you
22 appeared on This Week at ABC after you left
538
1 the White House up to the point that you
2 received the subpoena from Judicial Watch?
3 A I'm almost positive I didn't, but I
4 can't swear to it right now.
5 Q But you never checked, correct?
6 A I don't know what you're getting
7 at.
8 Q Yes or no?
9 A On ABC there's videotapes for
10 everyone to see.
11 Q Just answer the question.
12 A I've answered the question.
13 Q Did you ever check as to whether
14 you discussed Filegate?
15 A I don't know what it would be that
16 I would check.
17 Q Whether you discussed Filegate.
18 A What would I check?
19 Q Well, when you sit on the set with
20 your pen you make notes sometimes, don't you?
21 A Sometimes I doodle, sometimes I
22 write stars.
539
1 Q Sometimes you write notes, correct?
2 A I've never made a note about
3 Filegate. To the best of my recollection,
4 I'm pretty sure I haven't.
5 Q But you have made notes about
6 things that you were discussing on This Week?
7 A I have no idea what this has to do
8 with the judge's order to talk about the
9 adequacy of my document search.
10 Q Are you going to respond to that
11 question?
12 A I take notes sometimes before I go
13 on. I don't have any notes about Filegate.
14 Q You take notes sometimes when
15 you're on; that's where you have the pen in
16 your hand, correct?
17 MR. BRAND: He's answered that
18 question.
19 MR. KLAYMAN: You're not going to
20 let him answer?
21 MR. BRAND: It's been asked and
22 answered, Larry.
540
1 MR. KLAYMAN: Are you going to let
2 him answer the question.
3 MR. BRAND: The clock is ticking,
4 Larry. If he can.
5 THE WITNESS: I do sometimes have a
6 pen.
7 BY MR. KLAYMAN:
8 Q And you do sometimes make notes
9 contemporaneous with your appearance on This
10 Week?
11 A No, because I lose my
12 concentration. I might make a note before I
13 go on. No, I don't talk and write at the
14 same time. I try to avoid that.
15 Q The question was is if there's a
16 particular topic while you're on TV and you
17 think of something, you jot it down with a
18 pen, correct?
19 A Sometimes.
20 Q You do that?
21 A Sometimes I do; sometimes I don't.
22 Q And you don't know whether you've
541
1 made such notes with regard to Filegate up to
2 the point that you received the subpoena?
3 A I don't think I did and if I did
4 what I do is I throw those notes out after
5 every show, anyway. They're not -- you know,
6 they're not important. They're just little
7 memory reminders.
8 Q Are you saying that what you say on
9 ABC's This Week isn't important?
10 A That's not what I said. I said the
11 notes I use are not important because there's
12 a transcript for the whole world to see and
13 everybody's watching on TV.
14 Q They may not be important to you
15 but they're important to us. That's why I'm
16 asking you about it.
17 A They're not important because
18 they're not about FBI files.
19 MR. KLAYMAN: Certify it.
20 BY MR. KLAYMAN:
21 Q Do you keep tapes of all the ABC
22 shows?
542
1 A I have no idea what that has to do
2 with the judge's order but no, I don't.
3 Q Does anyone do it for you?
4 A No.
5 Q So you don't videotape your
6 appearances each week?
7 A No, I do not. My parents might.
8 Q Turn your attention to Exhibit 3 to
9 your last deposition. Have you seen Exhibit
10 3 before?
11 A Yes.
12 Q When you did your search on
13 February 16, did you have Exhibit 3 with you?
14 A Yes.
15 Q Look at request 1, page 4. Did you
16 find any documents or things responsive to
17 number 1?
18 A No.
19 Q Did you find any documents or
20 things responsive to number 2?
21 A They weren't in those files. I
22 mean, I've seen them from my lawyer before.
543
1 But I've seen them before.
2 Q Your lawyer has copies of these
3 documents?
4 A Of the ones from the judge, I
5 assume so, yeah.
6 Q Have you ever received a subpoena
7 from an Independent Counsel concerning
8 Filegate or any matter related to Filegate?
9 MR. BRAND: Objection as to
10 relevance.
11 MR. KLAYMAN: It's ordered to be
12 produced.
13 THE WITNESS: I didn't find any.
14 Had I found one -- I actually don't really
15 remember but I didn't find any.
16 BY MR. KLAYMAN:
17 Q Have you ever testified on Filegate
18 before anyone else other than Judicial Watch?
19 A No, I don't -- I can't remember.
20 But I didn't find any documents.
21 Q Did you ask your lawyers to search
22 for any documents that were responsive to
544
1 this subpoena in complying with the court's
2 orders of May 28, 1998?
3 A I think I misunderstood your
4 previous question. I thought when I read
5 number 2 it had to do with this subpoena. I
6 don't believe I have any other subpoenas.
7 Q But you don't know whether your
8 lawyers have them, do you?
9 A I actually don't know what my
10 lawyers have.
11 Q You never asked your lawyers to
12 search for documents responsive to Exhibit 3,
13 did you?
14 A I assume my lawyers saw the
15 subpoena, and if he had anything he would
16 produce it.
17 Q But you never made that specific
18 request, correct?
19 A Well, he's my lawyer. I follow his
20 -- I mean, I do what he tells me to do.
21 Q Did you make that specific request,
22 yes or no?
545
1 A I don't believe I made that
2 request.
3 Q Do you know whether your lawyer did
4 search for documents responsive to Exhibit 3?
5 A I know I did my search and I don't
6 believe I have any documents.
7 Q Do you know whether your lawyer did
8 a search?
9 A I don't know that. But, as I said,
10 I think I misunderstood your question.
11 Q Number 4, any all records,
12 correspondence, notes, communications, or
13 other documents concerning or relating to
14 communications to or from Jane Sherburne,
15 Esquire, concerning or relating to the access
16 to and disclosure of FBI background
17 investigation files or summary reports on
18 former Reagan and Bush administration
19 employees and others. Did you find any such
20 documents?
21 A I searched my files on February 16
22 and found no such documents.
546
1 Q Do you keep documents in your desk
2 drawer in Columbia University?
3 A No.
4 Q Did you search your desk drawers?
5 A I don't keep documents in my desk
6 drawer and I didn't look through my desk but
7 I don't have anything there.
8 Q What do you mean, you looked
9 through your desk?
10 A I look through my desk all the
11 time. I open it up, I'm sitting there, I
12 look here, I look there. I didn't have
13 anything.
14 Q But you didn't do it in response to
15 these orders?
16 A I've searched every place that I
17 thought it was conceivably possible that
18 there would be a document, and it's not
19 there.
20 Q Did you do it in response to these
21 orders?
22 A I looked at my desk on that day,
547
1 yes, I did.
2 Q Looked at your desk?
3 A I looked in the drawers of my desk
4 that day and I did not find any documents.
5 Q Is there a blotter on your desk?
6 A No.
7 Q Other than file cabinets, do you
8 keep documents in any other location in your
9 office?
10 A No, not really. I mean, there's
11 some on the shelves, but those are things
12 from my classes. Anything that came from the
13 White House time would be in those.
14 Q Did you search your shelves?
15 A I looked at my shelves. I don't
16 have anything.
17 Q Did you actually go through the
18 documents one by one?
19 A I went through my shelves and
20 looked at the various categories and I don't
21 have anything from Jane Sherburne.
22 Q Did you go through the documents
548
1 one by one on the shelves?
2 A I went through the documents
3 category by category and folder by folder and
4 I don't have anything.
5 Q Are you going to answer that
6 question or not?
7 A I just did.
8 Q You went through each piece of
9 paper one by one, the documents on the
10 shelves, to see whether you had anything on
11 Filegate, yes or no?
12 A I looked at the documents on my
13 shelves. I've looked at all the documents.
14 I don't have anything.
15 Q You looked through them one by one?
16 A I don't know what you mean by that.
17 I looked at the documents on my shelves.
18 Q Each page.
19 A If there is a book on Thomas
20 Jefferson's presidency, I didn't look at each
21 page in the book, no.
22 Q I've asked for documents, not for
549
1 books.
2 A I've answered that question.
3 Q You said you had papers on your
4 shelves?
5 A If I have documents on my class on
6 the Kennedy Presidency, I did not look
7 through every page for a note from Jane
8 Sherburne.
9 Q Have you taught classes at Columbia
10 that talk about things other than the Kennedy
11 Presidency?
12 A I've never taught a class at
13 Columbia that -- I've never discussed FBI
14 files at Columbia at all.
15 Q What are the topics of your
16 classes?
17 A Presidential promises.
18 Q Presidential promises. And what
19 that does mean?
20 MS. SHAPIRO: Objection, relevance.
21 BY MR. KLAYMAN:
22 Q You can respond.
550
1 A I look at every Presidency from
2 Kennedy to Clinton. I take a specific
3 campaign promise for each president and then
4 see what happened to it.
5 Q One of the President's promises was
6 that he was going to have the most honest and
7 ethical administration?
8 A That's not the one I chose. I did
9 welfare reform.
10 Q I understand why you didn't choose
11 it but did you discuss it?
12 MR. BRAND: You're wasting our time
13 again, Larry. That has nothing to do with
14 the adequacy of his search.
15 MR. KLAYMAN: He said he had papers
16 on his shelf, Presidential promises, the
17 Clinton administration --
18 MR. BRAND: He didn't say all that.
19 You're jumbling things together. Stick to
20 what he's testified to.
21 THE WITNESS: I can say for the
22 record that on questions 4, 5, 6, 7 --
551
1 BY MR. KLAYMAN:
2 Q Mr. Stephanopoulos, I will ask the
3 question. Certify this. This is part of our
4 motion for sanctions. We will ask the
5 questions.
6 A On questions 8, 9, 10, 11, 12, 13,
7 14, 15, 16, 17 and 18 and 19 and 20 and 21
8 and 22 and 23 and 24 and 25 and 26 and 27 and
9 28 and 29 and 30 and 31 and 32 and 33 and 34
10 and 35 and then 38 and 37 and I did not find
11 any documents after a thorough search
12 responsive to those questions.
13 Q There's no question pending,
14 Mr. Stephanopoulos. The question was did you
15 ever discuss in any of your classes at
16 Columbia University the issue of allegations
17 that this President had not been honest?
18 MR. BRAND: Objection.
19 BY MR. KLAYMAN:
20 Q Have you ever discussed that?
21 MR. BRAND: Objection and instruct
22 him not to answer. You're wasting our time
552
1 again, Larry.
2 BY MR. KLAYMAN:
3 Q Certify it. You keep tapes of all
4 your classes?
5 MR. BRAND: Larry, this deposition
6 is over.
7 MR. KLAYMAN: All right, certify
8 it. We'll move for sanctions.
9 THE VIDEOGRAPHER: We're going off
10 video record at 11:28.
11 (Whereupon, at 11:28 a.m., the
12 deposition of GEORGE
13 STEPHANOPOULOS was adjourned.)
14 * * * * *
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22